Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
TDS - challenge to the notices / summonses issued u/s 201 - no order u/s 201(i) can be passed for which limitation had already expired prior to amended section 201(3) as amended by Finance Act No.2 of 2014 - The impugned notices / summonses held to be invalid, quashed and set aside - HC
TDS - challenge to the notices / summonses issued u/s 201 - no order u/s 201(i) can be passed for which limitation had already expired prior to amended section 201(3) as amended by Finance Act No.2 of 2014 - The impugned notices / summonses held to be invalid, quashed and set aside - HC
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